The Role of the Chief Safety Officer in Public Transportation Agency Safety Plan Implementation
In light of the extraordinary challenges presented by the COVID-19 public health emergency, on December 11, 2020 FTA issued a second Notice of Enforcement Discretion for the Public Transportation Agency Safety Plan (PTASP) regulation (49 CFR Part 673). FTA will refrain from taking enforcement action until July 21, 2021 for recipients and subrecipients unable to certify compliance with the PTASP regulation. Please visit FTA’s COVID-19 FAQs page for more information about the Notice.
The PTASP TAC remains available to help you meet PTASP regulation requirements.
The Role of the Chief Safety Officer in Public Transportation Agency Safety Plan ImplementationHenrika Buchanan, FTA’s Acting Associate Administrator for the Office of Transit Safety and Oversight and Chief Safety Officer
In July 2018, the Federal Transit Administration (FTA) issued the Public Transportation Agency Safety Plan (PTASP) final rule, requiring certain transit operators to implement safety plans based on Safety Management System (SMS) principles.
Many of you have noted that SMS may introduce new roles or further connect existing roles within your transit agency. One of those roles is that of the Chief Safety Officer (CSO) or SMS Executive. Under the PTASP rule, a transit agency’s Accountable Executive must designate a CSO who is “adequately trained” and reports directly to him or her. A direct line of communication is critical and required because the Accountable Executive has the authority to make resource and personnel decisions.
Each agency may choose which type of training the CSO/SMS Executive will complete to qualify as “adequately trained.” One option is to enroll the CSO/SMS Executive in FTA’s Public Transportation Safety Certification Training Program. More information is available on FTA’s Safety Training website.
The rule also says that a transit agency may allow the Accountable Executive to serve as the CSO/SMS Executive. However, the CSO/SMS Executive may not serve in other operational or maintenance capacities unless the agency is a small public transportation provider as defined by the PTASP rule.
The CSO/SMS Executive may vary from agency to agency, but in general, they manage the transit agency’s safety function such as compliance with federal, state, and local regulations, and overseeing safety requirements for transit projects. Duties might also include hazard management, accident investigation, coordination with the State Safety Oversight Agency, and safety certifications.
The CSO/SMS Executive might also serve as the agency’s SMS subject matter expert. This may include developing an SMS implementation plan for the transit agency, coordinating with key staff to support SMS implementation, facilitating the development of SMS processes and activities, procuring technical resources for SMS implementation, communicating SMS implementation progress and challenges to the Accountable Executive, and socializing SMS activities with other executives and staff.
The CSO/SMS Executive role may look different at a large transit agency than it does at a small agency. At a rail transit agency or a large bus-only agency, the CSO/SMS Executive is a full-time role dedicated to ensuring safety and managing SMS implementation and does not have additional operational or maintenance responsibilities. At a small transit agency, the CSO/SMS Executive may have other functions, such as operations, maintenance or grant administration. They may be a part-time, full-time, or contracted employee of the transit system.
If your organization is ready to designate a CSO/SMS Executive and is wondering what to do next, consider these steps:
Start identifying SMS implementation roles and responsibilities for the appropriate staff
Have senior management designate key staff who will support SMS implementation
Ensure that key staff receive SMS training
Develop an SMS implementation plan, and communicate it throughout the organization
Brief your board of directors, oversight entities, and planning partners on SMS and your agency safety plan
If you have a State Safety Oversight Agency, discuss the SMS implementation plan with them
Remember, the PTASP final rule does not require your agency to have a fully mature SMS by the July 20, 2020 compliance deadline. Rather, FTA expects that transit agencies will have the processes and procedures put in place for SMS. Designating your CSO/SMS Executive now, selecting the staff who will support them, and getting them SMS training will help set your agency on the right path.
For additional PTASP resources such as FAQs, webinar registration information and recordings, and guidance and templates, please visit FTA’s PTASP website. You may also contact Candace Key, FTA’s Director for the Office of System Safety at Candace.Key@dot.gov or 202-366-9178 for more information.
Thank you for your continued commitment to strengthening transit safety.